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Stan T. Yamamoto <br />January 28, 2002 <br />Page 2 <br /> <br />City's environmental consultant to find an effective, cost-conscious technical solution. Should <br />this track result in approval of a very low cost remedy, we might avoid a good deal of the legal <br />work just enumerated. Second, I would expect to continue the dialogue begun last summer with <br />the City's insurance companies in the hopes of securing at least partial funding for the cleanup <br />and funding for a substantial portion of the litigation expenses. <br /> <br /> With regard to the fees likely to be incurred during 2002, I would estimate the low <br />end of the range at $75,000 to $100,000 With the high end of the range at $150,000-$200,000 <br />(before insurance payments and assuming that no low cost technical solution presents itself). <br />Where this matter falls in that range will depend primarily on the approach adopted by Roy's, <br />it's counsel, and the various insurance companies. One of the reasons I propose to work toward <br />a court-supervised mediation is precisely to minimize discover)- disputes, insurance company <br />posturing, and similarly wasteful activities. It should also be noted that these estimates assume <br />that no additional parties are added to the matter. <br /> <br /> I hope this letter provides the information you need, and I would be happy to <br />discuss any aspect of it with you. <br /> <br /> Very truly yours, <br /> <br /> Robert P. Doty <br /> <br />35874~20797vl <br /> <br /> <br />